Distance Selling Policy

Date Issued	June 2025
Version	1.0
Accountable Executive	Chief Revenue Officer
Owner	Director of Risk & Compliance
Next Review Date	June 2026

 

1. PURPOSE

This Distance Selling Policy establishes guidelines for Radius Vehicle Solutions employees to ensure compliance with legal requirements and best practices when conducting distance selling of vehicle leasing arrangements to business customers and sole traders. The policy protects both the company and customers by providing clear, transparent processes for all remote transactions.

Related Documentation: FCA Consumer Credit Sourcebook (CONC), Customer Complaints Policy, Data Protection Policy

2. DEFINITION OF DISTANCE SELLING

Distance selling refers to the conclusion of hire purchase agreements, finance leases, and operating leases with business customers without simultaneous physical presence of seller and customer, including:

·         Online applications through the Radius Vehicle Solutions website or customer portal

·         Telephone applications processed by our sales and credit teams

·         Email transactions for quotes, applications, and contract completions

·         Digital contract execution via electronic signature platforms

3. SCOPE OF APPLICATION

This policy applies to all employees involved in distance selling of:

·         Car leasing to businesses and sole traders

·         Commercial vehicle leasing to business customers

·         Fleet management services offered remotely

·         Ancillary services such as maintenance packages and insurance products

Coverage includes UK domestic transactions and, where applicable, international business customers operating in the UK.

4. LEGAL FRAMEWORK

As an FCA-regulated firm, employees must comply with:

·         Consumer Credit Act 1974 (where applicable to sole traders)

·         FCA Consumer Credit Sourcebook (CONC)

·         Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013

·         UK General Data Protection Regulation (UK GDPR)

·         Electronic Commerce (EC Directive) Regulations 2002

·         FCA Principles for Businesses

Note: Business-to-business transactions are generally exempt from consumer protection regulations, but sole trader customers may have consumer rights depending on the nature of their business use.

5. CUSTOMER INFORMATION AND TRANSPARENCY

Before agreement conclusion, customers must receive clear information on:

·         Total cost including monthly payments, initial payments, and any fees

·         Vehicle specifications and delivery timeframes

·         Lease terms including mileage allowances, maintenance responsibilities, and end-of-term obligations

·         Early termination costs and procedures

·         Insurance requirements and arrangements

·         Contact information for ongoing account management

·         Complaints procedure and Financial Ombudsman Service details

All information must be provided in a clear, prominent manner and be easily accessible throughout the application process.

6. RIGHT TO CANCEL

Consumer Customers (Sole Traders acting as consumers):

·         Right to cancel within 14 calendar days from agreement conclusion

·         Cancellation possible by email, telephone, or written notice

·         Must acknowledge cancellation within 24 hours

Business Customers:

·         Generally no statutory right to cancel once agreement concluded

·         Any cooling-off period must be contractually agreed and clearly stated

·         Pre-delivery cancellations subject to commercial terms

Withdrawal from Credit Applications:

·         Customers can withdraw credit applications before acceptance without penalty

·         Clear procedures must be communicated during application process

7. RETURNS AND REFUNDS PROCEDURE

For Consumer Cancellations:

·         Vehicle must be returned in original condition allowing for reasonable inspection

·         Customer responsible for return costs unless vehicle is defective

·         Refund initial payments within 14 days of vehicle return

·         May charge for diminished value due to handling beyond reasonable inspection

For Business Customers:

·         Returns governed by contractual terms

·         Early termination charges apply as per agreement

·         Vehicle condition assessed against fair wear and tear guidelines

Credit Application Withdrawals:

·         No charges for withdrawn applications

·         Delete application data as per data retention policy

8. EXEMPTIONS FROM THE RIGHT TO CANCEL

The following are typically exempt from cancellation rights:

·         Business-to-business agreements (companies, partnerships, LLPs)

·         Agreements already commenced with customer consent (vehicle delivered and in use)

·         Bespoke leasing arrangements specifically tailored to customer requirements

·         Ancillary services such as insurance where cover has commenced

These exemptions must be clearly communicated during the sales process and documented in customer records.

9. DELIVERY AND HANDOVER PROTOCOLS

Pre-Delivery:

·         Confirm delivery arrangements and location with customer

·         Provide vehicle documentation and handover checklist

·         Ensure customer has appropriate insurance coverage

·         Confirm driver license validity and any restrictions

Delivery Process:

·         Complete vehicle inspection with customer

·         Explain vehicle features and lease obligations

·         Obtain signed delivery receipt and any outstanding documentation

·         Provide emergency contact information

Risk Transfer: Risk and responsibility transfer to customer upon delivery acceptance and signing of delivery documentation.

10. CONTACT INFORMATION

Customer Service:

·         Email: leasingsalessupport@radiusvehiclesolutions.com

·         Phone: 01664 494000

·         Address: Radius Vehicle Solutions, Six Hills Business Park, Six Hills, Leicestershire LE14 3PD

·         Hours: Monday-Friday 8:30 AM - 5:00 PM

Credit Applications: leasingsalessupport@radiusvehiclesolutions.com

·         Email: leasingsalessupport@radiusvehiclesolutions.com

·         Phone: 01664 494000

Response Commitments:

·         Email enquiries: Within 24 hours during business days

·         Credit applications: Decision within 2 working days

·         Complaint acknowledgment: Within 3 working days

11. DATA PROTECTION

All customer data handling must comply with UK GDPR and FCA data protection requirements:

·         Lawful Basis: Processing necessary for contract performance and legal compliance

·         Credit Referencing: Obtain appropriate consent for credit searches and reporting

·         Data Sharing: Clear disclosure of data sharing with funders, insurers, and service providers

·         Retention: Maintain records for regulatory requirements (typically 6 years post-agreement)

·         Customer Rights: Facilitate access requests, corrections, and complaints

·         Credit Data: Special procedures apply for credit reference data and adverse credit reporting.

12. TRAINING AND AWARENESS

All customer-facing employees must receive:

·         Initial training on regulations and FCA requirements

·         Annual refresher training on policy updates and regulatory changes

·         Specific training on Consumer Duty and TCF principles

·         Credit training for staff involved in credit decisions

Training records maintained for FCA compliance purposes.

 

13. MONITORING AND REVIEW

Policy reviewed annually or when regulatory requirements change. Monitoring includes:

·         Customer feedback analysis and complaint trends

·         Regulatory updates from FCA and other relevant authorities

·         Sales process audits and compliance testing

·         Staff compliance assessments and mystery shopping

Results reported to senior management and used for continuous improvement.

14. ENFORCEMENT

Non-compliance may result in:

·         Disciplinary action up to and including termination

·         Regulatory breaches reportable to the FCA

·         Personal liability for serious compliance failures

·         Impact on FCA permissions and business operations

15. CONTACT FOR QUESTIONS

·         Head of Compliance

·         Email: compliance@radius.com

·         FCA Relationship Manager: Director of Risk & Compliance

Escalation: Senior management team (SMT) and Radius Compliance / legal counsel for complex matters.

 

Document Control NOTE:

This policy aligns with FCA requirements and must be reviewed following any regulatory updates. All employees must ensure they are working with the current version available on the company intranet.